The United States Anti-involvement with the ICC
Scotti Shafer
December 5, 2003
Edge Paper
Bruce Lusignan
The United States Anti-involvement with the ICC
Introduction to the ICC
“In the prospect of an international criminal
court lies the promise of universal justice. That
is the simple and soaring hope of this vision. We
are close to its realization. We will do our part
to see it through till the end. We ask you...to do
yours in our struggle to ensure that no ruler, no
State, no junta and no army anywhere can abuse
human rights with impunity. Only then will the
innocents of distant wars and conflicts know that
they, too, may sleep under the cover of justice;
that they, too, have rights, and that those who
violate thus rights will be punished.”1
Kofi Annan, UN Secretary-General
The Twentieth Century was the bloodiest in record history
with over 174 million people killed in mass murders and
genocides; more often then not, victims’ cries went unanswered.2
Following World War II the United Nations realized the need to
take action in ending impunity from these horrible crimes
against humanity.
With one of the primary objectives of the
Establishment of an International Criminal Court – Overview. November 20, 2003.
http://www.un.org/law/icc/general/overview.htm
2
www.USAforICC.org
1
2
United Nations being to secure “universal respect for human
rights and fundamental freedoms of individuals throughout the
world,”3 the United Nations recognized the need to establish an
international criminal court.
In 1948, at the Convention on the
Prevention and Punishment of the Crime of Genocide, the General
Assembly stated, “Recognizing that at all periods of history
genocide has inflicted great losses on humanity; and being
convinced that, in order to liberate mankind from such an odious
scourge, international cooperation is required.”4
However, it
was not until 1994 that the International Law Commission,
appointed by the General Assembly, completed a draft statute for
an international criminal court.
Finally, in July of 1998 the
international community met in Rome to finalize the draft
statute, which is now referred to as the Rome Statute of the
ICC.
The primary goals of the International Criminal Court are
to achieve justice for all, to end impunity, to help end
conflicts, to remedy the deficiencies of ad hoc tribunals, to
take over when national criminal justice institutions are
unwilling or unable to act, and to deter future war criminals.
“For nearly half a century – almost as long as the
United Nations has been in existence – the General
Assembly has recognized the need to establish such a
court to prosecute and punish persons responsible for
crimes such as genocide. Many thought… that the
horrors of the Second World War – the camps, the
3
4
ibid.
ibid.
3
cruelty, the exterminations, the Holocaust – could
never happen again. And yet they have. In Cambodia,
in Bosnia and Herzegovina, in Rwanda. Our time – this
decade even – has shown us that man’s capacity for
evil knows no limits. Genocide… is now a word of our
time, too, a heinous reality that calls for a historic
response.”5
Kofi Annan, UN Secretary-General
Statement of Purpose
This paper will clearly lay out the Unites States concerns
with the International Criminal Court and will attempt to
resolve them.
I will then argue that no country has the right
to be above international law, including the United States and
that it is in the best interest of America and the world
community for the united states to join the efforts of the ICC
and sign the Rome Statute.
Overview of the United States Position
Is United States foreign policy more concerned about what
is in the best interest of the United States or about what is in
the best interest of our world community?
The United Nations
has created an International Criminal Court to oversee the
preservation of world peace.
The ICC’s specific agenda is “to
prosecute the most serious breaches of global humanitarian and
human rights law: crimes against humanity, war crimes and
5
ibid.
4
genocide.”6 Though the Clinton administration supported the
efforts of the ICC and signed the Rome Treaty on December 31,
2002, the Bush administration has withdrawn the United States
from the ICC by unsigning the Rome Treaty on May 6, 2002.
In
deciding not to participate, the United States has cited the
following reasons: the ICC would undermine America’s ability to
defend its military and participate in peacekeeping activities,
fear that a world court would be used as a political weapon,
concern that the ICC has not yet “defined crime of
‘aggression,’”7 a belief that the ICC “is an institution of
unchecked power,”8 and that the ICC would take away from domestic
judicial systems.
In addition, an unstated concern of the
United States is that the ICC provides no benefit to the United
States, while at the same time threatening our sovereignty.
Although the United States puts forth some valid objections and
concerns, no country ought to be above international law including the United States.
Ushani, Agalawatta. “Politics: U.N. Members Say World Court No Threat To U.S.” Oct. 25,
2002. LexisNexis. Nov. 2, 2003. http://web.lexis-nexis.com/universe/document?
7
Zagaris, Bruce. “U.S. Announces that It Will Unsign and Take Action Against ICC.” July
2002. LexisNexis. November 3, 2003. http://web.lexis-nexis.com/universe/document?
8
Stated by Mark Grosman
6
5
A Closer Look at the United States and the ICC:
Seeing Both Sides
The U.S. fears that the ICC creates a political weapon
against the United States, especially for developing nations who
disapprove of United States policies.
Since the United States
is the world’s only remaining superpower, it fears that by
becoming a member of the ICC, the United States would lose
power.
By joining the ICC, the United States fears that
American leaders could be subject to trial by the ICC.
The
Undersecretary of State, John Bolton stated, “The issue is one
that directly affects individual Americans and quite possibly
the highest decision-makers of our country, who could be hauled
before this court and be subject to criminal penalties.”
Along with this fear, the Bush Administration is concerned
that the ICC is full of unchecked powers.
Marc Grossman, Under
Secretary for Political Affairs, explains that the Rome Treaty
“places enormous unchecked power in the hands of the ICC
prosecutor and judges, especially since the self-initiating
prosecutor is answerable to no state or institution other than
the Court itself.”
The U.S. fears that by giving the ICC this
much power it is going to weaken the power of the U.N. Security
Council and of the United States government.
6
Since the United States is such a powerful country, it is
understandable that it is concerned about politically motivated
ICC prosecutions; however, there have been adequate safeguards
against politically motivated accusations built into the Rome
Statute, “including thorough extensive United States input into
devising checks and balances, precisely in order to preclude
politically-motivated prosecutions.”9
One example of a safeguard
in the Rome Statute is in article 8 where the court focuses on
war crimes “committed as part of a plan or policy or as part of
a large-scale commission of such crimes.”
It is articles like
these that offer the United States protection.
Deborah Chatsis,
a member of the United Nations said, “The Rome Statute is a
carefully balanced instrument which fully respects the
sovereignty of law-abiding states willing and able to fulfill
their existing legal obligations to investigate and, where
necessary, prosecute those who commit the most heinous crimes.”
As long as the U.S. maintains the high law-abiding road they do
not have to fear prosecution from the ICC.
The United States also fears that the ICC will infringe on
the sovereignty of our nation by failing to promote domestic
judicial systems.
The United States does not disagree with the
ICC in whether a person or group of people who commit serious
Heinbecker, Paul. “U.S. Peacekeepers Not Above the Law.” August 2002. LexisNexis.
November 3, 2003. http://web.lexis-nexis.com/universe/document?
9
7
crimes in regard to the international community should be
punished.
The U.S. believes that an International Court could
and should develop a global strengthening of justice and rule of
law; however, the United States believes it is primarily the job
of the individual countries to ensure justice and secondarily
the responsibility of an international institution.
Grossman
stated, “We [The United States] believe that the best way to
combat theses serious offenses is to build domestic judicial
systems, strengthen political will and promote human freedom.”
This individualist stance taken by the U.S. is primarily based
on the threat that the overarching powers of the ICC would have
on America.
The United States fears that less powerful
countries are going to use the ICC to “proactively balance the
economic, military and diplomatic power of the United States.”10
By signing the Rome Statute, the United States will be giving
the ICC final authority on judicial matters.
American policy
makers fear this would not only take power away from the
American Supreme Court but also infringe upon the rights that
every American is guaranteed in the U.S. Constitution.
In contrast to the United States concerns, the ICC does not
take precedent over individual countries unless serous matters
were left ignored.
The Rome Statute of the ICC states that it
Davenport, David. “Commentary: New Threat to U.S. Sovereignty. United Press
International.” August, 2003. Lexis Nexis. http://web.lexis-nexis.com/universe/document?
10
8
places the primary job of investigation and prosecution with
domestic jurisdictions.
Therefore, the ICC does not take the
place of domestic jurisdiction.
“The ICC will not replace
national courts, but will be complementary to national criminal
jurisdictions. The Court will only investigate and prosecute if
a State is unwilling or unable to genuinely prosecute.”11
In
other words, the ICC may only exercise jurisdiction where
impunity would otherwise result.
that is built into the ICC.
This is a procedural safeguard
Also under the ICC, the United
States would still hold their own troops accountable for their
actions.
Because of this accountability clause, if the United
States feared having an American national tried by the ICC, then
the United States could investigate or try the suspect.
Along
the same lines, if a state or prosecutor wants to refer a case
to the ICC regarding an American, they must first notify the
United States.
The United States then has the decision to
undertake its own investigation, and the ICC has no jurisdiction
to step in unless the prosecutor proved the proceeding to be a
sham.
This accountability clause guaranties the U.S. Supreme
Court’s primary jurisdiction over American citizens.
While the
ICC gives the U.S. the primary responsibility of investigating
and trying Americans, the ICC is still a stable and
11
The Roman Statute of the ICC: Jurisdiction. November 3, 2003.
http://www.icc.int/en/ICC_jurisdiction.html
9
constitutional institution.
In fact, the United States was
heavily involved in the negotiations of the Rome Statute, and
consequentially, the Statute almost mirrors the United States’
Constitution.
The Roman Statute “provides individuals accused
of heinous crimes, as well as victims, nearly all of the
protections offered by the U.S. Constitution.”12
Below is a
chart comparing the United States’ Constitution to the rules of
the International Criminal Court:13
ROME TREATY
Presumption of Innocence
"Everyone shall be presumed to be
innocent until proven guilty before
the Court . . ."(Art. 66)
Speedy and Public Trial
" . . .the accused shall be entitled
to a public hearing . . .""the accused
shall be entitled . . . to be tried
without undue delay; . . ."(Arts.
67(1), 67(1)(c))
Assistance of Counsel
"…the accused shall be entitled…to
communicate freely with counsel of
accused's choosing…""…the accused
shall be entitled… to have legal
assistance assigned by the Court where
the interests of justice so require,
and without payment if the accused
lacks sufficient means to pay for
it;…"(Arts. 67(1)(b), (d))
12
13
U.S. CONSTITUTION
"The principle that there is a
presumption of innocence in favor of
the accused is the undoubted law,
axiomatic and elementary, and its
enforcement lies at the foundation of
the administration of our criminal
law."Coffin v. United States, 156 U.S.
432, 453 (1895)
"In all criminal prosecutions, the
accused shall enjoy the right to a
speedy and public trial, . .
."(Amendment VI)
"In all criminal prosecutions, the
accused shall enjoy the right…to have
the Assistance of Counsel for his
defense."(Amendment VI)
www.USAforICC.org
ibid.
10
Right to Remain Silent
"…the accused shall be entitled…not to
be compelled to testify or to confess
guilt and to remain silent, without
such silence being a consideration in
the determination of guilt or
innocence;…"(Art. 67(1)(g))
Privilege Against Self-Incrimination
"…the accused shall be entitled…not to
be compelled to testify or to confess
guilt…"(Arts. 54(1)(a), 67(1)(g))
Right to Written Statement of Charges
"…the person shall be provided with a
copy of the…charges…"(Art. 61(3))
Right to Examine or Have Examined
Adverse Witnesses
"…the accused shall be entitled…to
examine, or to have examined…the
witnesses against him or her…"(Art.
67(1)(e))
Right to Compulsory Process to Obtain
Witnesses
"…the accused shall be entitled…to
obtain the attendance and examination
of witnesses on his or her
behalf…"(Art. 67(1)(e))
Prohibition against Ex Post Facto
Crimes
"A person shall not be criminally
responsible…unless the conduct in
question constitutes, at the time it
takes place, a crime within the
jurisdiction of the Court."(Art. 22)
Protection against Double Jeopardy
"No person who has been tried by
another court…shall be tried by the
Court with respect to the same
conduct…"(Art. 20)
Freedom from Warrantless Arrest and
Searches
"…the Pre-Trial Chamber
may…issue…warrants as may be
required…""…if it [the Pre-Trial
Chamber] is satisfied that there are
reasonable grounds to believe that the
person has committed a crime…and the
arrest of the person appears
necessary…"(Arts. 57 bis (3), (58))
"No person…shall be compelled in any
criminal case to be a witness against
himself…"(Amendment V)
"No person…shall be compelled in any
criminal case to be a witness against
himself…"(Amendment V)
"In all criminal prosecutions, the
accused shall enjoy the right…to be
informed of the nature and cause of
the accusation;…"(Amendment VI)
"In all criminal prosecutions, the
accused shall enjoy the right…to be
confronted with the witnesses against
him;…"(Amendment VI)
"In all criminal prosecutions, the
accused shall enjoy the right…to have
compulsory process for obtaining
witnesses in his favor,…"(Amendment
VI)
"No Bill of Attainder of ex post facto
law shall be passed."(Art. I, sec. 9,
cl. 3)
"…nor shall any person be subject for
the same offence to be twice put in
jeopardy of life or limb;…"(Amendment
V)
"[N]o Warrants shall issue, but upon
probable cause…"(Amendment IV)
11
Right to be Present at Trial
"The accused shall be present during
the trial."(Art. 63)
Exclusion of Illegally Obtained
Evidence
"Evidence obtained by means of a
violation of this Statute or
internationally recognized human
rights shall not be admissible…"(Art.
69(7))
Prohibition against Trials in absentia
"The accused shall be present during
the trial."(Art. 63)
"one of the most basic of the rights
guaranteed by the Confrontation Clause
is the accused's right to be present
in the courtroom at every stage of his
trial."Illinois v. Allen, 397 U.S.
337, 338 (1970)(Citing Lewis v. United
States, 146 U.S. 370 (1892))
When evidence is obtained in violation
of the Fourth Amendment, the
judicially developed exclusionary rule
usually precludes its use in a
criminal proceeding against the victim
of the illegal search and
seizure.Illinois v. Krull, 480 U.S.
340, 347 (1987)(Citing Weeks v. United
States, 232 U.S. 383 (1914); Mapp v.
Ohio, 367 U.S. 643 (1961))
When defendant knowingly absents
himself from court during trial, court
may "proceed with trial in like manner
and with like effect as if he were
present."Diaz v. United States, 223
U.S. 442, 455 (1912)The language,
history, and logic of Rule 43 support
a straightforward interpretation that
prohibits the trial in absentia of a
defendant who is not present at the
beginning of trial.Crosby v. United
States, 506 U.S. 255, 262 (1993)
This chart clearly shows the similarities between the U.S.
Constitution and the Rome Statute.
The only right guaranteed by
the U.S. Constitution that is not guaranteed by the Rome Statute
is the right to a trial by jury.
This right is missing from the
Rome Statute due to the impracticality of impaneling a jury to
try international cases.
In view of this difference one must
keep in mind that “Far fewer due process protections are
guaranteed to American citizens accused of crimes abroad.
They
12
are subject to trial in foreign justice systems, many of which
do not provide for a jury trial or other valued due process
protections.”14
Also, “The United States has signed a number of
extradition treaties that specifically allow Americans to be
tried abroad in foreign courts without jury trials.”15
The Rome
Statute does not provide trials by jury; however, this, while it
may seem extreme, goes along with many of America’s current
foreign policy agreement.
The United States is also unwilling to join the ICC because
of its jurisdiction over crimes of aggression.
The Court’s
jurisdiction over crimes of aggression is clearly stated in
Article 5 of the Rome Statute.
It states, “The jurisdiction of
the Court shall be limited to the most serious crimes of concern
to the international community as a whole. The Court has
jurisdiction in accordance with this Statute with respect to the
following crimes: the crime of genocide, crimes against
humanity, war crimes, and the crime of aggression.” However, the
ICC “will not exercise such jurisdiction until the crime [of
aggression] has been further defined and conditions under which
the Court will exercise its jurisdiction have been agreed
upon.”16
The United States does not feel that the ICC should be
ibid.
ibid.
16
The Roman Statute of the ICC: Jurisdiction. November 3, 2003.
http://www.icc.int/en/ICC_jurisdiction.html
14
15
13
in a position to have jurisdiction over aggression because it
gives them the power to investigate and prosecute the “still to
be defined crime of ‘aggression.’”17
Since there is not yet
universal definition for the crime of aggression, the U.S. does
not feel that the ICC should be given the power to define this
crime and then become the prosecutor of crimes they have
defined.
In deciding not to join the ICC, the United States is not
removing itself from ICC jurisdiction, but is isolating itself
from the rest of the world and may well be starting the decay of
their ability to shape world policy.
ICC jurisdiction can be
given either by the territorial State (the State where the crime
took place), or the State of nationality.
So whether or not the
U.S. signs the ICC, U.S. nationals could still be subject to ICC
jurisdiction.
Thus, if an American national commits a war crime
on a territorial state, the case could be referred to the ICC
despite the fact the United States is not a member of the ICC.
This potential action may be the single most convincing reason
for the United States to join the ICC now.
The unsigning of the
Rome Treaty does not guaranty the Unites States sovereignty; it
simply gives the rest of the world a negative image of our
country. For example:
Zagaris, Bruce. “U.S. Announces that It Will Unsign and Take Action Against ICC.” July
2002. LexisNexis. November 3, 2003. http://web.lexis-nexis.com/universe/document?
17
14

No country has ever ‘unsigned’ a treaty in the history
of the United Nations.

The unsigning has strained US relations with allies
around the world.

Bush’s actions are viewed by European countries as an
isolationist move on behalf of the United States,
breaking away from its policy of human rights
concerns.

This decision establishes a bad precedence, and would
allow countries that have yet to ratify treaties that
are important to United States policy to ‘unsign’
themselves.

Unsigning the treaty poses problems for the validity
of future United States presidents.18
Contrastingly, by signing the Rome Treaty the United States
would have a say in important future decisions, such as the
selection of the 18 judges who will make up the ICC, and would
allow the U.S. a say in the interpretation and decision making
on the crime of “aggression.”
“The only way the US can protect its interests at the
Court is by actively participating in the Assembly of
States Parties so as to shape a strong and fair
institution that will protect US interests. The US
can have this kind of positive influence, as is shown
by it past work on the Court. Throughout its strenuous
participation in all the years of ICC negotiations,
the US made extensive contributions to the Court’s
present form. These include provisions giving strong
deference to national courts, the inclusion of almost
all of the US Bill of Rights, and definitions of
crimes in complete conformity with the US Uniform Code
of Military Justice. If the US continues to work
actively with the Court as an observer, player and
18
www.USAforICC.org
15
referee, it will have the position and authority to
guard itself against perceived threats. This will be
impossible if it undermines its influence and
credibility through active hostility or arbitrary
refusals to cooperate with the ICC.”19
On top of this, by joining the ICC the United States would be
making a strong symbolic stance, indicating to the rest of the
world that America does care about the rule of law everywhere
and will under no circumstances allow horrible crimes against
humanity.
Former president Bill Clinton stated, “[Signing the
Rome Treaty will] reaffirm our strong support for international
accountability and for bringing to justice perpetrators of
genocide, war crimes, and crimes against humanity.”20 Since the
United States has no choice but to be under the jurisdiction of
the ICC, it seems only logical that the U.S. should join and
become strongly involved in efforts to shape and form its
foundation to their own benefit.
Currently, the United States is undermining the efforts of
the ICC by making bilateral deals with other countries that will
exempt the United States from the Rome Statute of the ICC.
Article 98 of the Rome Statute provides immunity to both
military and civilian personnel by not allowing countries to
surrender individuals to the court for acts consistent with
obligations under another international treaty.
19
20
The United
ibid.
ibid.
16
States is manipulating Article 98 to protect treaties they are
making today to evade the ICC.
“The United States is
interpreting Article 98(2) as allowing them to strong-arm other
countries into exempting the U.S. from the International
Criminal Court’s jurisdiction with threats of withholding
military and economic assistance,” states Heather Hamilton, the
director of bilateral agreements.
Hamilton added that Article
98 was “in no way intended to provide immunity for the nationals
of one country from international justice.”
In their
manipulation of Article 98 and by deciding not to sign the Rome
Statute, the United States is sending a message that one has to
believe; the message that we are above the law.
On top of this, U.S. policy makers have failed to listen to
their own citizen’s views toward the International Criminal
Court.
“Within the Washington policymaking community, there is
a widespread assumption that the American public is very wary of
international cooperation and of the international institutions
that were built for that purpose,”21 such as the ICC. A study
taken by Market Strategies and Greenberg Research in April of
1993 shows that the majority of the American public is in
support of the ICC. Below is an example of a question from the
study:22
21
22
http://www.pipa.org/OnlineReports/Globalization/4.html
http://www.pipa.org/OnlineReports/Globalization/notes/allnotes_.html
17
83 Question: Some people think that the U.N. (United Nations) Charter should
be changed so that top leaders, such as heads of state in different
countries, could be arrested by the U.N. for certain serious crimes and then
tried by an International Criminal Court, and if judged guilty would be
punished. I am going to read you some things that leaders have done and ask
if you approve or disapprove changing the U.N. Charter to permit the U.N.,
upon due process of law, to bring leaders accused of these things to stand
trial by an International Criminal Court....[below]..Do you approve or
disapprove bringing that leader to trial in an International Court? (If
approve/disapprove, ask:) Would that be strongly or somewhat?
A leader who does serious damage to the global environment.
Strongly approve
68%
Somewhat approve
18
Somewhat disapprove
6
Strongly disapprove
6
Don't know
2
A leader who invades and occupies a neighboring country.
Strongly approve
69%
Somewhat approve
17
Somewhat disapprove
7
Strongly disapprove
6
Don't know
2
A leader who violates human rights, including making war on ethnic and other
groups in that leader's country.
Strongly approve
71%
Somewhat approve
16
Somewhat disapprove
5
Strongly disapprove
7
Don't know
1
A leader who prevents a democratic election from taking place.
Strongly approve
44%
Somewhat approve
24
Somewhat disapprove
18
Strongly disapprove
12
Don't know
2
A leader who acquires nuclear weapons.
Strongly approve
50%
Somewhat approve
17
Somewhat disapprove
17
Strongly disapprove
12
Don't know
4
18
This study along with many other similar ones is clear evidence
of the publics pro-stance toward the ICC.
Another study taken
in March 2000 by the Program for International Policy Attitudes
came out with the same results.
All in all, the Bush Administration and Congress need to take
into consideration the views of their citizens with regard to
the ICC.
As a democratic nation the actions of the United
States should be up to the people and not a small group of
policy makers.
19
Conclusion
The world is reeling from a century stained by unimaginable
carnage to humanity.
Our parents and grandparents suffered from
the evils of Hitler and the Holocaust, they have been horrified
by the Rwandan genocide, the racial purification in former
Yugoslavia, and Pol Pot’s slaughter of millions of Cambodians.
Now a new generation has been traumatized by the recent
terrorist attacks at ground zero.
From witnessing such
atrocities, we have learned a fundamental lesson; impunity from
such grievous crimes must end.
It is these horrific crimes
against humanity that created a world in need of an
international criminal court.
Nations must unite to send the
strongest of statements against impunity for the most serious
crimes.
The ICC “is an essential contribution to the
preservation of peace and the strengthening of international
security.”23
It is the humanitarian duty of the United States to
join the rest of the world in this struggle for peace, justice,
and universal human rights.
Margrethe, Ellen. “U.S. Peacekeepers Integral and Prosecutable.” August 2002. LexisNexis.
November 3, 2002. http://web.lexis-nexis.com/universe/document?
23
20
Work Cited
Establishment of an International Criminal Court – Overview.
http://www.un.org/law/icc/general/overview.htm
USA for the International Criminal Court. December 1, 2003.
http://www.USAforICC.org
Ushani, Agalawatta. “Politics: U.N. Members Say World Court No
Threat To U.S.” Oct. 25, 2002. LexisNexis. November 2,
2003. http://web.lexis-nexis.com/universe/document?
Zagaris, Bruce. “U.S. Announces that It Will Unsign and Take
Action Against ICC.” July 2002. LexisNexis. November 3,
2003. http://web.lexis-nexis.com/universe/document?
Heinbecker, Paul. “U.S. Peacekeepers Not Above the Law.” August
2002. LexisNexis. November 3, 2003. http://web.lexisnexis.com/universe/document?
Davenport, David. “Commentary: New Threat to U.S. Sovereignty.
United Press International.” August 2003. Lexis Nexis.
December 3, 2003. http://web.lexisnexis.com/universe/document?
The Roman Statute of the ICC: Jurisdiction. November 3, 2002.
Internet. http://www.icc.int/en/ICC_jurisdiction.html
PIPA. Americas on Globalization: A Study of US Public Attitudes.
International Cooperation. March 28, 2000. Internet.
December 4, 2003.
http://www.pipa.org/OnlineReports/Globalization/4.html
PIPA. Americans on Globalization. All Notes. Question 83.
December 2, 2003. Internet.
http://www.pipa.org/OnlineReports/Globalization/notes/allno
tes_.html
Margrethe, Ellen. “U.S. Peacekeepers Integral and Prosecutable.”
August 2002. LexisNexis. November 3, 2002.
http://web.lexis-nexis.com/universe/document?
21